Mail Stop 4561
      July 7, 2005

VIA U.S. MAIL AND FAX (615) 269-8461

Mr. Scott W. Holmes
Senior Vice President and Chief Financial Officer
Healthcare Realty Trust Incorporated
3310 West End Avenue
Suite 700
Nashville, TN  37203

      Re:	Healthcare Realty Trust, Inc.
      Item 4.01 Form 8-K
      Filed June 13, 2005
      File No. 001-11852

Dear Mr. Holmes:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may raise additional
comments.

      	Please understand that the purpose of our review process
is
to assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 8-K filed June 13, 2005

1. Refer to paragraph (d).  Revise the Form 8-K to provide the
disclosure required by Item 304(a)(iv)(A), (B) and (C) of
Regulation
S-K for the disagreement and reportable events.  Also, refer to
Item
304(a)(v)(A) of Regulation S-K.  Please file a revised Exhibit 16
letter.

2. Provide us with any letter or written communication to and from
the former accountants regarding any disagreements or reportable
events to management or the Audit Committee.

3. Please provide us with a schedule of your quarter end
adjustments
to close the books, or adjustments recorded in connection with or
as
a result of the reviews for the quarters ended March 31, June 30,
and
September 30, 2004.  Clearly explain the reason for each
adjustment.
For each adjustment, show us the impact on pre-tax net loss.
Quantify the net effect of all adjustments on pre-tax net
income(loss).  Also, tell us why none of the adjustments relate to
prior period.  Explain in detail why you believe the timing of
each
adjustment is appropriate.

4. When you engage a new accountant, please report the engagement
in
a new Form 8-K and comply with the requirements of Regulation S-K
Item 304 (a)(2).  In making any disclosures about consultations
with
your new accountants, please ensure you disclose any consultations
up
through the date of engagement.

Form 10-Q for the quarter ended September 30, 2004

Controls and Procedures

5. Supplementally, please tell us in detail how management came to
the conclusion that your disclosure controls were effective at the
end of the third quarter.  This is inconsistent with the fact that
in
Item 9A of exhibit 99.1 on Form 8-K filed June 24, 2005 management
came to the conclusion that your disclosure controls were not
effective as of December 31, 2004.

      File an amendment under cover of Form 8-K/A and include the
Item 4.01 designation, including the letter from the former
accountant filed as an Exhibit 16.  Please note that your former
accountants should make it clear within the Exhibit 16 letter that
it
is in reference to your amended Form 8-K.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

      In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	Please provide the supplemental information requested above
within 5 business days from the date of this letter.  The
supplemental information should be filed as correspondence on
EDGAR.
The amendment requested should be filed as promptly as possible
and
should be reviewed by the former accountants.  The letter required
by
Exhibit 16 should cover any revised disclosures.

Any questions regarding the above should be directed to me at
(202)
551-3466.



								Sincerely,



								Matthew Maulbeck
								Staff Accountant

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Healthcare Realty Trust, Inc.
July 7, 2005



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